Fill and Sign the Plaintiffs Names Form

-1- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 (Name, Address Of Party or attorney) _____________________________ _____________________________ _____________________________ State Bar No: __________________ (____) _____ - _________________ Attorney for _______ (Or "In Pro Per") SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ________ PLAINTIFF(S) NAMES ) CASE NO.: _______ Plaintiffs ) ) v ) ) DEFENDANT(S) NAMES ) Defendants and All persons Claiming Any Legal or Equitable Right, Title, Estate, Lien or Interest in the Property Described in the Complaint Adverse to Plaintiff’s Title, or any Cloud on Plaintiffs Title Thereto and DOES 1 Thr ough 10 Inclusive, Defendants ------------------------------------------------------- COMPLAINT TO QUIET TITLE AND FOR INJUNCTIVE RELIEF Plaintiff complains and for causes of action alleges as follows: I. Plaintiff __________ [name], is, and at all times mentioned in this complaint was, a resident of __________ County, California. -2- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 II. Defendant __________ [name], is, and at all times mentioned in this complaint was, a resident of __________County, California. III. Plaintiff does not know the true na mes of defendants. All Persons Unknown, Claiming Any Legal or Equitable Right, Title, Estate, Lien, or Interest in the Property Described in the Complaint Adverse to Plaintiff's Title, or Any Cloud On Plaintiff's Title Thereto and DOES 1 through 10, inclu sive, and therefore sues them by those fictitious names. __________ [Optionally, in addition to language in charging allegations that includes fictitiously named defendants: Plaintiff is informed and believes and on that basis alleges that each of the DOE defendants claims, or may claim, some interest in plaintiff's real property described in this complaint.] The names, capacities and relationships of DOES 1 through 10 will be alleged by amendment to this complaint when they are known. IV. Plaintiff is inf ormed and believes and on that basis alleges, that at all times mentioned in this complaint, defendants were the agents and employees of their codefendants, and in doing the things alleged in this complaint were acting within the course and scope of that a gency and employment. V. Plaintiff is the owner in fee and is in possession and control of real property and improvements located at __________ [location and street address of property], and more specifically described as __________ [set forth legal descr iption of real property]. VI. Plaintiff obtained fee simple title to the real property by a grant deed from __________ [name of grantor], which is dated __________ [include date of deed], and recorded as document number __________ in the official records of __________ County, California. -3- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 VII. Defendant __________ [named defendant] is the owner in fee and is in possession and control of real property and improvements located at _________ [location and street address of property], and more specifically desc ribed as __________ [set forth legal description of real property]. VIII. The above -described properties of plaintiff and defendant __________ named defendant] adjoin each other at the __________ [specify, such as: north] boundary of plaintiff's property and the __________ [specify, such as: south] boundary of __________'s [named defendant's] property. The true and correct boundary line between the properties of plaintiff and defendant __________ [named defendant] runs as follows: __________ [describe bo undary line that plaintiff contends is correct]. IX. Defendants claim an interest or estate in plaintiff's above -described property, or a portion of it, by disputing and denying that the true and correct boundary line between the properties of plaintiff a nd defendant __________ [named defendant] runs as described in paragraph 8 of this complaint. Plaintiff is informed, believes, and therefore alleges that defendants contend that the true and correct boundary line between the properties of plaintiff and de fendant __________[named defendant] runs as follows: __________ [describe boundary line that defendants claim to be correct]. The claim of defendants is without any right whatsoever, and defendants have no right, estate, title, or interest in the above -des cribed property of plaintiff, or any part of it. X. Plaintiff seeks to quiet title to the disputed portion of plaintiff's above -described property as of __________ [specify either the date of the filing of the complaint or state reasons why a determination of title as of a different date is sought]. -4- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 XI. Defendant __________ [named defendant] __________ [has wrongfully threatened to interfere or is interfering] with plaintiff's use of the disputed portion of plaintiff's above - described property and, in particular, has __________ [state nature of the threa tened or actual interference]. XII. Defendant __________'s [named defendant's] __________ [wrongful threat to interfere or actual and continuing interference], unless and until enjoined and restrained by order of this court, will cause grave and irreparab le injury to plaintiff in that plaintiff __________ [will be or is being] deprived of use of the disputed portion of plaintiff's above -described property. XIII. Plaintiff has no adequate remedy at law for the __________ [threatened or continuing] conduct in that it would be impossible for plaintiff to determine the precise amount of damage plaintiff will suffer if defendant __________'s [named defendant's] conduct is not restrained, and in that plaintiff will be deprived of the use of real property, which deprivation cannot be compensated in damages. WHEREFORE, plaintiff demands judgment against defendants as follows: That defendants be required to set forth each and every claim they may assert to plaintiff's above -described property; That this court det ermine the true and correct location of the boundary line between the above -described properties of plaintiff and defendant __________ [named defendant]. That plaintiff's title in and to plaintiff's above - described property be quieted, that it be adjudge d that the true and correct location of the boundary line between the above -described properties of plaintiff and defendant __________[named defendant] be as alleged by plaintiff in -5- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 paragraph 8 of this complaint, and that defendants be adjudged to have no right, title, estate, lien, or interest in or to the property of plaintiff, or any part of that property; For a temporary restraining order, a preliminary injunction, and a permanent injunction prohibiting defendant __________ [named defendant] from inter fering with plaintiff's use of the disputed portion of plaintiff's property; For attorney fees and costs incurred in this action; and For such other and further relief as this court may deem just and proper. DATE: ____________________ ______________ ______ (Signature) VERIFICATION I, ___, am a ___in the abo ve -entitled action. I have read the foregoing ___and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein alleged on information and belief, and as to those matters, I believe it to be true. I decla re under penalty of perjury that the foregoing is true and correct and that this declaration was executed at , California. DATE: ____________________ ____________________ (Signature)